“Emancipatory potential has been found in some traditional Indian norms as well as international human rights and domestic constitutional law and used in the battle against a remnant of colonial law. Litigation, social and political mobilisation, media attention and other factors have interacted and supported each other. Litigation started without waiting for popular and media support; in stead the process and outcome itself may have helped create such support. Litigation has also ended up being unsuccessful, however, due to the judges and other factors. Even so, it may still have contributed positively to the larger social and political mobilisation, as we saw after Koushal. While the combined result of the three landmark judgments is a complex and unclear legal situation for queer Indians, overall we seem to be moving in the direction of strengthened rights in the legal as well as the wider political and social contexts.”